United States v. Manning (Defense Exhibits)

DEPARTMENT OF THE ARMY

HEADQUARTERS AND HEAD QUARTERS COMPANY,
20 0ftQAD€ COMBAT TEAM,
10™ MOUNTAIN DIVISION (LI)

ADFR-BBA-1N . . 6 April 2011

MEMORANDUM THRU

Commander, 20 Brigade CojpfedfTeani, 10th Mountain Division (Light Infantry), Fort Drum,
New York 13602

Commander, I Oth Mojjjtf«tn~D] vision (Light Infantry), Fort Drum, New York 13602

FOR Commander, U.S. Army Combined Arms Center and Fort Leavenworth, Fort Leavenworth,
Kansas 66027

SUBJECT: Rebuttal of General Officer Memorandum of Reprimand - WO I Kyle J. Balonek

BLUF: The information contained in the General Officer Memorandum of Reprimand is
incorrect and does not accurately reflect the sworn statements and tacts presented in the 1 5-6
investigation. Therefore I respectfully request that this General Officer Memorandum of
Reprimand not be Hied in my Official Military Personnel File.

1 . I respectfully request that this statement be reviewed and considered before a final
determination is made regarding tiling of this administrative reprimand in accordance with Army
Regulation (AR) 600-37, paragraph 3-4<b)OXb).

2 . I acknowledge receiving this reprimand.

3. I have read and understand the unfavorable information presented against me and submit the
following on my behalf:

a. I served as PFC Bradley Manning's mid-level supervisor for only a short period of time.
While under my supervision any misconduct that was brought to my attention was dealt with
accordingly.

( I) Between April 2009 and July 2009 1 served as PFC Manning's mid-level supervisor
with SPC Showman as his direct supervisor and MSG Paul Adkins as his senior supervisor. SPC
Showman never brought to my attention PFC Manning's April 2009 outburst nor did she report
to me PFC Manning's March 2009 "no loyalty to country" statement. SPC Showman
circumvented me and reported the incidents directly to MSG Adkins (See Exhibit (E78-5) SPC
Statement ( 1 9JAN II)). On July 20, 2009 1 began my ASAS Master Analyst Course at Ft.
Huachuca, AZ (See Enclosure I). This course lasted until September 18, 2009 at which time I
took approximately ten days of leave. I returned to Fort Drum on September 28, 2009. Since I
was attending the Master Analyst Course, I did not go to JRTC with my brigade. Therefore 1 was

DEFENSE EXHIBI T^ f or identification
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SUBJECT: Rebuttal of General Officer Memorandum of Reprimand - WOI Kyle J. Balonek

unaware of PFC Manning's August 2009 outburst at JRTC. 1 deployed on October 1 1, 2009,
thirteen days after 1 returned to Fort Drum.

(2) During the process of deployment to Iraq, 1 again served as PFC Manning's mid-level
supervisor. However between October 1 1 , 2009 and November 1 2, 2009 he had no outbursts or
any other documented issues. To the contrary I specifically remember PFC Manning performing
well. While we were in Kuwait he showed up on time, always had all the proper gear and even
attended a First Sergeant's meeting for me, where he took excellent notes.

(3) Between November 12, 2009 and February 10, 2010 I was not PFC Manning's
supervisor since he was detailed to the night shift. During deployment an E-4 was the NCOIC of
the night shift and was directly overseen by MSG Adkins (See Exhibit (A) 1 5-6 Report 3-1-11
FINAL (2d Correction), Section IB: Chain of Command, pg. 26, Figure 3 and pg. 27). I had no
supervisory duties over the night shift personnel and all disciplinary actions were the
responsibility of the night shift NCOIC and MSG Adkins. During this period of time PFC
Manning had an outburst where he flipped a table. This incident was addressed by MSG Adkins
by sending PFC Manning to mental health.

(4) PFC Manning was put on the day shift when he returned from leave on approximately
February 10, 2010 and remained there until early April 2010. During this period of time I was,
on paper, considered the NCOIC of the day shift. However, MSG Adkins had assumed
responsibility for all personnel matters (See Exhibit (A) 15-6 Report 3-1-11 FINAL (2d
Correction), pg. 28). As the Senior Intelligence Sergeant, I was responsible for supervising all
intelligence production and ensuring quality control of all intelligence products (See Enclosure 2,
Part III, box a). According to MSG Adkins I was not responsible for personnel matters.
However, I still handled the day to day personnel matters if necessary. While PFC Manning was
on the day shift, under my supervision, his work products were excellent and he had no major
disciplinary problems. The only problem I encountered with PFC Manning while he was on the
day shift was his punctuality which I addressed with both verbal and written counseling
statements.

(5) PFC Manning returned to the night shift in early April 2010. While on the night shift
PFC Manning was supervised by SPC Showman and MSG Adkins. I remained the day shift
NCOIC and thus had no supervisory responsibility over PFC Manning. On May 7, 2010 PFC
Manning assaulted SPC Showman. MSG Adkins took the appropriate disciplinary action by
giving PFC Manning an Article 15. 1 left theater on May 27, 2010 to attend Warrant Officer
Candidate School

b. I had no knowledge of most of PFC Manning's personal and behavioral issues and I
addressed all the misconduct that was brought to my attention. The only behavioral issue I had
knowledge of while PFC Manning was under my supervision was his propensity to show up late
for duty. To correct this I gave him both verbal and written counseling statements. I had
knowledge of PFC Manning's December 2009 outburst where he flipped a table, as well as PFC

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SUBJECT: Rebuttal of General Officer Memorandum of Reprimand - WO I Kyle J. Balonek

Manning's assault on SPC Showman. However, both of these incidences occurred while PFC
Manning was on the night shift and the appropriate corrective action was taken by MSG Adkins.

(1) PFC Manning's Apiil 2009 outburst as well as his March 2009 "no loyalty to country"
statement to SPC Showman was reported directly to MSG Adkins (See Exhibit (E78-3) SPC
Statement (18JUN10) and Exhibit (E78-5) SPC Statement ( 19J AN 1 1)). These incidences were
never reported to me and 1 had no knowledge they had occurred.

(2) 1 also had no knowledge of PFC Manning's August 2009 outburst at JRTC. As stated
previously, 1 did not attend JRTC with my brigade since I was at the ASAS Master Analyst
Course at Ft. Huachuca, AZ. Additionally, this outburst was never reported to me when 1
returned to the unit on September 29, 2009.

(3) PFC Manning's April 24, 2010 4t my problem" email was addressed directly to MSG
Adkins(See Exhibit (EI-4) Email from SPC to MSG (24APRI0)). PFC Manning's statements in
that email were never reported or shared with me, thus I had no knowledge of his personal
issues.

c MSG Adkins created a situation where 1, as a supervisor, was circumvented in regards to
personnel matters. Not only was 1 intentionally circumvented by MSG Adkins, but the extent to
which 1 was being circumvented was also hidden from me I agree MSG Adkins did not relieve
me of my supervisory duties and I indeed continued to act as a supervisor for personnel matters
on the day shift. This is evidenced by my counseling of PFC Manning for being late to duty.
However, MSG Adkins had created a situation that made sure most issues with PFC Manning
were reported directly to him. MSG Adkins intentionally cut me out of all decision making and
disciplinary actions. My ability to supervise and take appropriate corrective action was
hampered by MSG Adkins supervisory scheme which made sure all direct supervisors reported
to him, rather than to me.

( 1 ) The J 5-6 investigation states that MSG Adkins "purposefully removed or impeded
other NCO's and Warrant Officers from participating in the decision making process, usurping
their supervisory responsibilities over enlisted soldiers within the section." (See Exhibit (A) 15-6
Report 3-1-11 FINAL (2d Correction), Section IB: Chain of Command, pg. 24).

(2) The 15-6 investigation also states that MSG Adkins changed the supervisory schemes
pre and post deployment which created a dysfunctional supervisory relationship among S-2 mid-
level leaders and enlisted soldiers (See Exhibit (A) 15-6 Report 3-1-11 FINAL (2d Correction),
Section IB: Chain of Command, pg. 24).

(3) Finally, MSG Adkins himself stated that he wanted to "ride out [PFC Manning's]
issues with therapy and hopefully [PFC Manning could] ETS with an honorable [discharge]"
(See Exhibit (El -5) (USD-C 380-5) MSG Statement ( 1 OJUN 1 0)) This statement shows that
MSG Adkins wanted to protect PFC Manning from any discipline by creating a supervisory

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SUBJECT; Rebuttal of General Officer Memorandum of Reprimand WO 1 Kyle J. Balonek

scheme which would circumvent mid-level supervisors and hid and diminish any misconduct
committed by PFC Manning.

d. I never knew of any instances where MSG Adkins failed to take appropriate corrective
action. As stated before, I was only aware of PFC Manning's problems with punctual ity, his
December 2009 outburst where he Hipped a table and his assault on SPC Showman, 1 took
appropriate action in the form of verbal and written counseling to correct PFC Manning's
problem with punctuality. MSG Adkins properly referred PFC Manning to mental health after
he flipped a table. MSG Adkins also took appropriate action in the form of an Article 15 and
removal fiom the SCIF when PFC Manning assaulted SPC Showman. I became aware of PFC
Manning's other incidences of misconduct only after receiving this memorandum of reprimand
and having the chance to review the 15-6 investigation and the accompanying sworn statements.

4. For the forgoing reasons, 1 respectfully request that you do not file this Memorandum of
Reprimand or, in the alternative, file this Memorandum of Reprimand in my local file rather than
in my Official Military Personnel File.

5. The point of contact for this memorandum is the undersigned at^^| |;@us,army.mil.

2 Ends

1. September 18, 2009 DA 1059

2. March 10.20I0NCOER

WOI, US Army
Respondent

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